Howard Nemaizer has, knowingly and
willfully, promoted false information in connection with the name and website of
Barbara Hartwell, since February 2014.

On December 15, 2014, I first made a
public request that he REMOVE all such false information, all fraudulent notices
on his websites and YouTube channel, in which the unauthorized use of my name,
website and likeness appeared.

Nemaizer chose to disregard my request.
In February, 2015, I issued a public demand that the false/fraudulent
information be removed.

Nemaizer's response was to publish a
defamatory notice, making false accusations against Barbara Hartwell, and
stating that:

"I will not spend hours deleting TRUSTED
PARTNERS IN TRUTH from more than 200 posts on this website going back to Feb
2014 at the request of Barbara Hartwell, unless she would like to pay me for my
time."

Nemaizer thus acknowledges the length of time (from
February 2014-February 2015) that the fraudulent notice has been published on
the Internet, and also that the number of posts containing the fraudulent
notices is "more than 200 posts". (These fraudulent notices have now been on Nemaizer's sites for a total of 21 months, thus increasing the damages to Barbara Hartwell.)

I
subsequently issued a formal warning to CEASE & DESIST from promoting the
fraudulent notices, the false information, and the exploitation of my name and
website in a false light, via his presentations, articles and
videos.

Specifically:

Howard Nemaizer has placed my name and website in a fraudulent notice,
"TRUSTED PARTNERS IN TRUTH", a list of names and websites (including "Truth Talk
News"), without my knowledge or consent.

FACT:
I have never, at any time, been a "partner" of anyone on this list, including
Howard Nemaizer aka Nema, nor had any affiliation whatsoever with anyone on this list.

FACT:
Howard Nemaizer was well aware when he first posted this notice that it was
false information, and that some of the names on the list were individuals whom
I had publicly denounced, for cause, including one Harry Link and one Janet
Phelan.

FACT:
Howard Nemaizer, in refusing to remove this fraudulent material, after one
request, several demands and a formal warning, has been acting with malice, by
knowingly continuing to exploit, misrepresent and defame my good
name, in disregard of my protests.

Howard Nemaizer has published a video (July 2014) in which my name is
exploited in connection to CIA operations, in which he presents false and
defamatory information about my background. He has refused to remove this video,
and it is still promoted on his website, Howard Nema dot com, as well as on
other sites.

Howard Nemaizer has unlawfully taken material from previously unpublished interviews of Barbara Hartwell, which he has published without my
knowledge or consent, thus violating a "good faith" verbal agreement regarding
these interviews, which were intended for the sole purpose of sale to the
public, thus depriving me of the related
income.

He
has stolen the fruits of my labor, as well as stolen the name I had chosen for
these interviews, "The Barbara Hartwell
Chronicles".

Howard Nemaizer has exploited my name, my work and my website, for his
own gain, while presenting material which places my name, website and work in a
false light, which is also defamatory.

Howard Nemaizer has also used my name and website on the same pages with
a career criminal/predicate felon named Keith Mutch, of UNITED FM Radio,
Torrington, CT, where "Truth Talk News" airs, thus making it appear that Barbara
Hartwell (listed falsely in "TRUSTED PARTNERS IN TRUTH") is connected not only
with "Truth Talk News", but with the individuals (including one Keith Mutch) who
own and operate this radio station.

I am
a government whistleblower (former CIA) and journalist whose work has been
published on the Internet (since 1995) via print and electronic media.

Howard
Nemaizer's promotions of false information, fraudulent notices and stolen
material have been directly responsible for a plethora of damages; have
been injurious to my good name and reputation; have caused severe emotional distress, due to
the falsehoods attributed to me by Nemaizer; for invasions of my privacy, and by
exploitation of my name and website.

This
formal complaint is posted here, for the public record, and will be sent to the
administrators of Wordpress, blogspot, YouTube, with additional details
of the violations and abuses of terms of service by Howard
Nemaizer.

Here,
some excerpts relevant to my formal complaint, from this
website:

The
unwarranted appropriation or exploitation of one’s personality, the publicizing
of one’s private affairs with which the public has no legitimate concern, or the
wrongful intrusion into one’s private activities, in such manner as to outrage
or cause mental suffering, shame, or humiliation to a person of ordinary
sensibilities.

This (U.S. Supreme) Court has approved the following as a
fairly comprehensive definition of what constitutes an actionable invasion of
the right of privacy:

Defamation is
generally defined as a statement impeaching the honesty, integrity or reputation
of an individual and thereby exposing the individual to public hatred, contempt
or ridicule, to cause him or her to be shunned or avoided or to injure the
individual in his or her office, business or
occupation.

Defamation is written
or spoken injury to the reputation of a living person or organization. Injury to
reputation generally is considered to be exposure to hatred, contempt, ridicule,
or financial loss. Libel is the written act of defamation; slander is the spoken
act. This distinction is important; libel often has greater legal consequences
than slander. Whether libel or slander, the defamation must be published –
communicated to someone other than the subject of the defamation. . .
.

"False Light" privacy lawsuits occur
when a writer publishes facts about a person that creates a deliberately false
and misleading impression. Examples include when a newspaper publishes a story
about convicted felons and includes the name or photograph of an innocent
person, or when, in a story about a hate group, the writer includes the
name of a person not a member of that
group.